The principles of this paragraph (l) are illustrated by the following examples. In each example, assume that Company X is a U.S. corporation and Company Y is a wholly-owned subsidiary of Company X in Country B ...

A controlled services transaction may be analyzed as two separate transactions for purposes of determining the arm’s length consideration, if that analysis is the most reliable means of determining the arm’s length consideration for the controlled services transaction. See the best method rule under § 1.482-1(c) ...